Comment on OMB-2026-0034-0001
Good Willed Consulting LLCOpposeBusiness
Summary: Katelynn Z Regner, a grant professional, opposes the proposed rule because she believes it replaces objective, merit-based grant reviews with subjective political oversight. She argues that the rule creates financial instability for local organizations, risks political favoritism, and could lead to the coercion of nonprofits into conforming to national ideologies.
RE: Joint Proposed Rule: Regulation for Federal Financial Assistance (89 FR 46722 / RIN 1900-AA00)
Docket ID: OMB-2026-0034-0001
To Whom It May Concern,
I am writing to submit my formal comment in strong opposition to the proposed rule titled Regulation for Federal Financial Assistance, published on May 29, 2026. As a resident of Baltimore, Maryland, and a grant professional who works nationally, I am deeply concerned that this proposed overhaul of the Uniform Guidance framework will fundamentally destabilize local communities, erode public trust, and compromise the integrity of federal spending.
While I support efforts to ensure taxpayer dollars are spent efficiently, the proposed shift to grant senior political appointees final veto authority over individualized, competitive federal grants introduces profound risks to local organizations and the everyday people they serve. I urge the Office of Management and Budget (OMB) and its partner agencies to withdraw this proposal based on the following critical concerns:
1. The Invalidation of Objective Merit-Based Review
For decades, the integrity of federal grantmaking has relied on rigorous, nonpartisan peer-review panels and career experts. This ensures that public funds are allocated based on technical merit, scientific validity, and verified community need. By making these expert evaluations strictly "advisory" and allowing political appointees to override or alter final scores, the rule replaces objective criteria with subjective political preferences. Taxpayer funds should go to the most qualified applicants, not those with the most favorable political alignment.
2. Arbitrary Disruptions to Essential Local Services
The provision allowing the administration to terminate existing, multi-year grants at any time—without a transparent or robust appeals process—creates an untenable environment for local organizations. Small nonprofits, local health centers, law enforcement agencies, and schools rely on financial predictability to maintain operations. If a grant can be abruptly cancelled mid-cycle due to shifting national political winds, local communities will bear the immediate consequences of lost services, layoffs, and halted public works.
3. Coercion and Ideological Litmus Tests for Local Entities
By explicitly restricting funding based on specific social, ideological, or organizational philosophies—and subjecting grantees' outside affiliations to heightened scrutiny—this rule forces local organizations into a state of self-censorship. Small, grassroots nonprofits that intimately understand their neighborhoods' needs should not have to alter their mission statements or conform to a centralized national ideology just to secure the resources required to serve their communities. This top-down control fundamentally undermines local autonomy.
4. Increased Vulnerability to Waste and Political Favoritism
Proponents argue that centralized control increases accountability. In reality, dismantling the firewall between political campaigns and administrative funding distribution achieves the exact opposite. Giving political appointees the explicit power to manually select grant winners creates a direct vulnerability for favoritism, where federal assistance can be weaponized to reward political allies or penalize dissenting regions. This severely damages public trust in federal institutions.
Conclusion
The proposed regulations threaten to transform a system built on fairness and expertise into one governed by political compliance. It places an unfair, unpredictable burden on the very organizations tasked with delivering critical services to the American public.
I strongly urge OMB and the cooperating departments to preserve the integrity, predictability, and nonpartisan nature of the federal financial assistance system by withdrawing this proposed rule.
Thank you for your time and consideration of these comments.
Sincerely,
Katelynn Z Regner